On July 21, the U.S. Treasury Department (“Treasury”) released temporary and proposed regulations denying a basis increase to equity holders of lessee partnerships and S corporations to account for mandatory income inclusions...more
On May 5, the U.S. Treasury Department released Notice 2016-31 to address certain changes made to the Production Tax Credit (“PTC”) and Investment Tax Credit (“ITC”) in the Protecting Americans from Tax Hikes (“PATH”) Act of...more
On May 10, 2016, India and Mauritius signed a protocol amending the India-Mauritius double income tax treaty that would, among other things, permit India to tax a Mauritian resident on capital gains arising from the sale of...more
Over the past several years, Congress has sought to incentivize investment in small businesses by allowing taxpayers to exclude gains in certain small business stock sales. Gradually, Congress continued to increase these...more
This alert provides an overview of various timber tax issues in play as part of the tax reform debate. The alert is drawn from several sources, including former House Ways and Means Committee Chairman David Camp’s tax reform...more
On December 30, 2013, the Internal Revenue Service (the “IRS”) released Revenue Procedure 2014-12, which sets out a new “safe harbor” for allocations of the historical rehabilitation credit (the “HRC”) among partners in a...more
On September 20, 2013, the U.S. Department of the Treasury (“Treasury”) released Notice 2013-60, which clarifies in important ways the eligibility rules applicable to the investment tax credit (“ITC”) and production tax...more
On November 3, 2010 and January 18, 2011, we issued client alerts discussing the opportunities provided by the Section 1202 exclusion from tax on gain realized on the sale of certain stock issued by a “qualified small...more